RIA Compliance Manual
NCCI assists you in the preparation of compliance manuals, including updates, and notices.
Every Investment Adviser must develop and maintain written procedures that define the supervisory process the firm implements to assure compliance regarding:
- Acting on Insider Information
- Chinese Wall procedures, if applicable
- Trade allocation
- Monitoring personal securities transactions
- Pricing and valuation procedures
- Proxy voting procedures, if applicable
- Procedures to follow in the event of errors
Your firm may elect to define and implement a compliance system beyond the minimums required. Since your firm must conduct its business in accordance with certain regulations and rules, and to assist you in internal verification of compliance, you may find it useful to place these procedures in written form.
Note, however, that whatever you put in writing and represent as your procedures must be accurate. The procedures define what you actually do at your firm. As you modify and redefine your procedures, so must you revise your manual. Regulators will refer to your own procedures to verify that you are in compliance.
This compendium is known as the firm’s “Compliance Manual” or “Compliance Guide”. It must be tailored to the firm, its products, offices and supervisory personnel. The compliance manual is a guidebook for use by supervisory personnel in attempting to assure compliance with the requirements of the Investment Advisers Act of 1940, the rules and regulations arising from the Act, as well as relevant state regulations. In addition to a brief description of what a firm is required to, it further defines “Who” does “What”, “When” something is to be done, and “How” you evidence you have done it.
NCCI creates, reviews and revises Compliance manuals to include the most current rule requirements and related procedures. We produce manuals in a “Who” does “What” “When” and “How” format for easy reference and simple use. And, because of the overall structure, our manuals are easily amended when necessary.
If you require a Compliance Manual as part of your Investment Adviser application, NCCI offers an excellent product – complete, current, easily used, easily understood, and easily amended.
No Investment Adviser is currently required by regulation to have an “Operating Procedures Manual” or a “Policy and Procedures Manual.” Depending on its size, a firm may find one or the other useful. These manuals are different from a compliance manual in that the former defines each job at a firm in functional terms, while the latter defines how the firm attempts to assure compliance with the governing regulations.
If you firm has grown such that it employs a number of operations personnel, as well as a growing list of registered professionals, it may be advisable to consider a firm specific Procedures Manual.
It establishes how your registered representatives set up accounts, what documents are required to open an account, how they are to enter orders, prepare and send communications, etc. Essentially, it describes the “back office” functions of your firm in a manner that facilitates simplified cross training or job substitution for personnel on leave, vacation or otherwise absent.
Since it describes the procedures of job functions specific to your firm, it must accurately describe what is done and what you want to be done at your firm.
If you require a Compliance Manual as part of your Investment Adviser application, to meet a state requirement, or to become an SEC registered adviser NCCI offers an excellent product—complete, current, easily used, easily understood, and easily amended.